Summary: | 碩士 === 中原大學 === 財經法律研究所 === 93 === Abstract
The main subject of this thesis is“The Study On Tax Advance Ruling System-A Supplementary Comment on the Promise in German Tax Law”as the question, carrying on the writing of master's thesis, the following is that the content per chapter is explained roughly :
Chapter one is the introduction, prove to research motive and purpose , research range , method and thesis structure.
Chapter two is the evaluation and analysis of“Tax Advance Ruling System”, announce on our country Ministry of Finance“Tax Advance Ruling System”expound the fact and analyze, focus on the legislative purpose, the definition of advance ruling, the procedure documents and the entity documents , the legal result of advance ruling, the fresh deliberation of advance ruling , stop the application of advance ruling.
Chapter three is the promise(Zusage) in German tax law , recommend and analyze the promise in German tax law, expect to clear up the comparison that the system there can be foreign legal system to compared, especially in our country that the administrative lawsuit is different from America and England . At this point, this chapter can be subdivided into the definition of promise concept and demarcation line, the legal nature of promise, the scope of application promising to be promised about the right、obligation , the summary one before permission that is promised in tax law, refusal asked for and promised to be permitted, offer legitimacy important document , constrained strength , the general promise (allgemeine Zusage ) and other promises in tax laws.
Chapter four is compare and analyze with the focal point of German legal system for the legal system of our country, after the discussion, this thesis thinks that we should comment the better foreign legal system to our country, and offer the suggestion of revising to tax advance ruling system.
Chapter five is conclude the speech , which makes and describes the explanation the result of study proposed mainly.
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